How Coronavirus (COVID-19) affects UK private pilots

During the current crisis, there has been a stream of notices, advice and guidance from the CAA, EASA and pilot organisations. It can be difficult to filter out the specific issues that affect private pilots, i.e. those with PPL, LAPL etc. and also spot what’s missing. It’s very easy to mix these up with derogations for commercial pilots. The CAA has provided some exemption guidance in a simpler and easier to digest summary format in CAP1319.

I’ve tried to simplify and clarify the key points below. This is a fairly fast changing situation, so while I have done my best you should beware that the statements below may already be incorrect or out of date.

Current government guidance on coronavirus now permits recreational GA flying in England while in other UK regions it’s limited to ground runs, monthly engine health flights and other technical maintenance work to keep equipment serviceable is permitted. Social distancing measures prevent flying with anyone other that from your household, so this precludes flight instruction and most buddy flying. Aircraft owners, including those with group shares, and renters are able to fly solo with many clubs/groups relaxing their currency requirements for the first flight on the basis of some refresher reading material. Landaways are possible, although not all airfields are open, but you may find it better (and some clubs may mandate) that your first flight is a local one if you haven’t flown recently.

Rating expiry dates extended to 22 November

For those with an EASA LAPL or PPL, if your SEP, IRR or IR rating was valid on 16 March 2020but expires before 31 October then it can be extended to 22 November based on a ground briefing from an instructor (which can be provided remotely). This also applies to non-EASA UK only licence holders including NPPL, UK PPL, UK CPL and UK ATPL where the rating expires before 31 July 2020. [ORS4 1385 for EASA licences, ORS4 1384 for UK licences]

For those who return to flying with an expired rating, then a short flight with an examiner will be required. This is a proficiency check rather than a skill test and can/should include some element of instruction. Although many pilots prefer to avoid anything considered a test, perhaps combining this with a general de-rusting/club check may be no bad thing.

For LAPL holders, the running expiry window is extended from 24 months to 32 months, also subject to the ground briefing from an instructor mentioned above. Failing that, you could choose between a proficiency check with an examiner and gaining the required recency by flight with and under supervision of an instructor. The benefit of the proficiency check is that it fully resets your LAPL currency for two years and you can immediately carry passengers.

The measures above will let you return to flying for the current season, but you will again have to revalidate your SEP rating before it expires on 22 November. To do that by experience, you’ll need to log the usual 12 hours flight time of which at least 6 are PIC, one is with an instructor and 12 take-offs/landings. The time period to log that remains the last 12 months prior to rating expiry, so that means between 22 November 2019 and 22 November 2020.

Temporary Certificates extended to 6 months

The one exception to the above is for those who have just passed their skill test or Assessment of Competence. If they have a temporary certificate issued by their examiner, the validity period has been extended from 8 weeks to 6 months, to allow the CAA to process their documentation. [ORS4 1373]

Medical Certificate expiry dates extended to 22 November

If your Class 2 or LAPL medical has expired, it won’t be possible to renew it in person at the moment. AME’s are closed apart from exceptional circumstances, and it’s been made clear that when they open priority will be given to commercial pilots.

In the circumstances, the CAA has issued an extension for those with valid medical certificates held on 16 March 2020 which expire before 31 October 2020 to be extended through to 22 November 2020. [ORS4 1370]

In any case, if you normally have a Class 2 medical, you may find it comes with a longer LAPL validity. You can legally fly using a PPL licence and LAPL medical anywhere in Europe, restricted to LAPL privileges only. However, that excludes acting as Flight Instructor/Examiner or flying IFR in an EASA aircraft.

You don’t need to apply for this extension, although you could carry a printed copy of the official notice (linked above) in case you were challenged. In my view, that’s unlikely to be a problem when in the UK.

Personal Medical Declaration

The PMD was introduced in 2016 and allowed PPL and LAPL holders to avoid the need to visit an AME. Provided they are healthy enough to drive a commercial truck and don’t suffer from one of a specific range of ailments, then can self-declare themselves as such. A one-off declaration is valid until aged 70, thereafter every three years. There is no cost to make a declaration, it just takes a few minutes on the CAA website. You must print out and carry the resulting declaration document with you alongside your pilot licence.

These cannot be used for flights outside the UK or for instructors/solo training.

The PMD is valid for both EASA and non-EASA aircraft. This privilege will remain valid for non-EASA aircraft permanently. It was recently extended to cover EASA aircraft up to November 2019, but only if the declaration was made on or before 8 April 2020. [ORS4 1370]

UK PPL and NPPL no longer valid for EASA aircraft

It’s been some time in coming, but finally the deadline has passed. EASA has slowly been enforcing the requirement to hold an EASA licence to fly an EASA aircraft. This has been adopted quickly in many European countries, where there typically is no other licence available above that for a microlight.

In the days before pan-European regulations and licences from JAR and EASA, the UK simply issued its own ICAO compliant licences. These older UK PPLs remain valid even today, although most pilots would have converted.

The UK chose to issue their own national UK PPL licence when EASA licences were introduced, arguing that these were required to hold any non-EASA ratings. It has caused a lot of confusion, duplication and excessive bureaucracy. I can’t say I’m aware of any UK specific ratings that need this anymore, and with hindsight perhaps it has been a complexity that perhaps could have been avoided.

We also have the inconveniently named NPPL (National PPL Licence), which was a forerunner of the European LAPL. These can host a microlight rating (which is what most micropilots would have) and/or an SSEA rating (which allows the holder to fly a larger fixed wing aircraft).

As of 7 April 2020, none of the above three types of licence can be used to fly an EASA aircraft. The derogation that was given to enable that was not renewed. These licences remain valid for non- EASA aircraft and I don’t know of any plans to remove or discontinue them.

Aircraft Hibernation

Aircraft like to be flown and used regularly. Long periods of downtime can cause rusting and degradation of the engine in particular, condensation in the fuel tanks and depletion of the batteries. While ground runs may be an option, “winterisation” seems to be the popular recommendation – effectively hibernating the aircraft.

This typically involves adding a litre or so of inhibiting oil, perhaps changing the oil beforehand, removing the spark plugs and spraying something into the cylinders, as well as disconnecting the battery. When next flying, the inhibiting oil can be left it to burn off. The procedure takes perhaps an hour or so and involved running the aircraft up to temperature. It’s not entirely straightforward and may not be for you, so consult a professional engineer.

Alternatively, for owners in Scotland/Wales/Northern Ireland, the CAA has sanctioned Engine Health flights to avoid engine degradation during downtime, which have some confusing and conflicting requirements to remain in the circuit, but as high as possible and within 10 miles of the airfield.

Aircraft Insurance

If not being flown, aircraft insurance can be downgraded to “Ground Risks Only”, saving 60-70% of the annual cost. There are typically three risk categories: Flight, Taxying and Ground, so if you do expect to taxi your aircraft then retain the insurance risk for that otherwise revert to Ground only.

Aircraft Maintenance Regulations

There have been no alleviations or extensions for maintenance timescales. Aircraft Annuals, ARCs, 50 hour services (which also have a six month timeframe) all continue to apply. Your aircraft may not be legal to fly even if it has few hours since last service.

A significant change came into effect for light aircraft during March 2020, with the introduction of Part ML. For those flying private operations in aircraft less than 1200kg only (i.e. not flight training or commercial operations), this has less impact.

However, all flight schools and those owners of aircraft 1200kg or more will need to develop their own AMP (Annual Maintenance Program) and have this approved by their CAMO. An ARC (Annual Review Certificate) may not be able to be issued without one.

Many CAMOs may choose to downgrade to CAOs, which have fewer requirements but retain the most useful privileges required for general light aviation aircraft including ability to approve an AMP.

This is quite a complex change but has been poorly communicated to engineers and owners, so do read up on it and study the implications during the transition.

Students

Pilots in training could make good use of the downtime to study for their theory exams.

PPL and LAPL students will find that the introduction of e-Exams has been postponed from June. The existing paper exam questions will continue for the time being. Several clubs (DTOs) are now able to conduct these with social distancing measures in place, although the more advanced CPL/IR/ATPL exams have been suspended.

The maximum period of 18 months to pass all your PPL/ATPL theory exams have been extended by 6 months to 2 years. [ORS4 1353]

Thanks David for the time spent trawling thru the often ambiguous text in CAA docs, as did John.
It is appreciated and the latest extensions shows a glimmer of light to reduce complexity for and the demand placed on the regulators keeping all sorts of red-tape scenarios simple. Hope you and family all well, Allan